E-liquids

Refill liquids for electronic cigarettes, with or without nicotine, including bases, flavour concentrates and DIY boosters where the market treats them the same way.

Open Tobacco law

verified 10.07.2026 · TPD Pro regulatory desk

Not every value on this page is confirmed.

Fields carrying a Draft marker come from a measure that is not in force. Fields carrying Needs check have not yet been verified at source. Both are marked individually next to the value, and the open questions are listed at the foot of this page.

Position

Where this stands, in words.

Open Permitted; the notification regime functions.

Regulated under the tobacco act and its technical decree, transposing article 20 of the TPD. Excise has applied since 1 April 2025 at a rate that steps with nicotine strength. Cross-border distance selling is prohibited; domestic online sale is possible on conditions.

Commercial sale Open

RD 579/2017

Online sale Open

Domestic online sale is possible with a Spanish domicile, age verification and EU-CEG notification.

Ley 28/2005; RD 579/2017

Cross-border distance sale Banned

Ley 28/2005, disposición adicional duodécima

Requirements

Every parameter, with its source.

A field with no source is not shown at all — not shown with a caveat, not shown. Anything missing from this table is missing because it has not been verified, not because it does not apply.

Legal basis

Base law The act the category is governed by in this market.: Ley 28/2005, as amended by RD-ley 17/2017

Ley 28/2005 boe.es verified 10.07.2026
Implementing act The decree, regulation or ordinance carrying the detail.: Real Decreto 579/2017, as amended by RD 47/2024

RD 579/2017 boe.es verified 10.07.2026
EU-level regulation Whether and how the category is covered by EU law. A category outside EU law is regulated market by market, with no common floor.: Directive 2014/40/EU (TPD2), art. 20 — transposed

Directive 2014/40/EU, art. 20 boe.es verified 10.07.2026
Competent authority Who regulates, who supervises, and who receives the filing.: Ministerio de Sanidad; Dirección General de Salud Pública

sanidad.gob.es verified 10.07.2026

Composition and limits

Maximum nicotine The ceiling on nicotine content, in the unit the act sets it in.: 20 mg/ml

RD 579/2017 boe.es verified 10.07.2026
Container volume Ceilings on refill container and tank or cartridge volume.: Refill container 10 ml; tank 2 ml maximum

RD 579/2017 boe.es verified 10.07.2026
Prohibited ingredients Substances that may not be present, beyond the general prohibition on hazardous ones.: Characterising flavours, vitamins, caffeine, taurine, colourants, additives facilitating nicotine uptake, toxic substances, and CBD or cannabinoids

RD 579/2017 boe.es verified 10.07.2026
Flavour restriction Whether characterising flavours are restricted, and from when. One of the most widely misreported fields in this sector.: None in force. The draft royal decree would permit tobacco flavour only Draft

Proyecto de Real Decreto — draft, not in force sanidad.gob.es verified 10.07.2026

Packaging and labelling

Mandatory warning The statutory wording. Reproduced verbatim in the language of the act, because the text on the pack must match it.: Este producto contiene nicotina, una sustancia que crea una gran dependencia.

RD 579/2017 boe.es verified 10.07.2026
Warning format Surface share, placement and any accompanying age mark.: 30% of the external surface of the pack of the pack surface

RD 579/2017 boe.es verified 10.07.2026
Other packaging requirements Leaflet, child resistance, tamper evidence, and prohibited presentation.: Child and tamper protection; a leaflet (folleto); text in Spanish; the pack is filed with the Dirección General de Salud Pública

RD 579/2017 boe.es verified 10.07.2026

Notification

Notification channel Where the filing goes. Not an assumption: some markets take these products outside EU-CEG entirely, and some have no channel at all.: EU-CEG, via the Dirección General de Salud Pública

RD 579/2017 boe.es verified 10.07.2026
Lead time How far ahead of market entry the notification must be filed.: 6 months before market entry

RD 579/2017, arts. 6–7 boe.es verified 10.07.2026
Data required What has to be in the dossier.: Composition and emissions by brand and type; toxicology; nicotine doses; the refill mechanism

RD 579/2017; Decision (EU) 2015/2183 boe.es verified 10.07.2026
Registry and status check Where a product's approval status can be confirmed.: Registro de Fabricantes, Importadores y Distribuidores

RD 579/2017 boe.es verified 10.07.2026

Sales

Minimum age The age below which sale is prohibited.: 18 years

Ley 28/2005, art. 3 boe.es verified 10.07.2026
Online and distance sale Whether the product may be sold remotely, domestically and across borders.: Cross-border distance selling prohibited; domestic online sale possible with a Spanish domicile, age verification and EU-CEG notification

Ley 28/2005, disposición adicional duodécima boe.es verified 10.07.2026

Excise and chemicals

Advertising What promotion is permitted, if any.: Substantially restricted, on the same footing as tobacco

Ley 28/2005; RD-ley 17/2017 boe.es verified 10.07.2026
Excise The rate and its basis of assessment. Five markets use four different units, so the unit travels with the figure.: 0.15 up to 15 mg/ml; 0.20 above 15 mg/ml €/ml

In force since 01.04.2025. The rate steps with nicotine strength, which is unusual: most markets charge a flat rate per millilitre.

Ley 7/2024; Orden HAC/86/2025 boe.es verified 10.07.2026
Excise mechanism Who is liable, what marking is required, and through which system.: Declared to the AEAT on form 573 Needs check

agenciatributaria.es verified 10.07.2026
Excise territory Where the excise applies, when a market's tax territory is not the whole state.: Mainland Spain and the Balearic Islands. Not the Canary Islands, Ceuta or Melilla

Ley 7/2024 boe.es verified 10.07.2026
Chemicals legislation REACH, CLP, safety data sheets and poison-centre notification, which apply in parallel to the product regime.: REACH and CLP apply; safety data sheet required; national RD 1468/1988

Regulation (EC) 1907/2006; Regulation (EC) 1272/2008 boe.es verified 10.07.2026

Mandatory warning

The statutory wording, verbatim.

Reproduced exactly as the act sets it, in the language it sets it in. The text on your pack has to match this character for character, so it is never paraphrased and never machine-translated here. Where an English gloss is given it is unofficial and is not the text to print.

Spanish · es

Este producto contiene nicotina, una sustancia que crea una gran dependencia.

unofficial gloss — This product contains nicotine, a substance that creates a strong dependence.

RD 579/2017 boe.es

Commonly misreported

What the internet gets wrong.

widely reported

Spain limits nicotine pouches to 0.99 mg and permits only tobacco-flavoured e-liquids.

what the source says

Both figures come from a draft royal decree that is not in force. It is still in the TRIS procedure as notification 26624, and its final text and transitional periods are unsettled. Designing a product to a draft limit and shipping before it commences means complying with a rule that does not yet exist while possibly missing the one that does.

Proyecto de Real Decreto — draft sanidad.gob.es

widely reported

Spanish excise on liquids and pouches applies throughout Spain.

what the source says

It applies in mainland Spain and the Balearic Islands only. The Canary Islands, Ceuta and Melilla are outside the excise territory and operate their own indirect tax regimes. Shipments between the mainland and those territories carry their own declaration requirements.

Ley 7/2024 boe.es

Not in force

What is coming for this category.

None of this is law today.

Draft

Draft royal decree amending RD 579/2017

A draft. It is not law and does not bind anyone.

Would set a 0.99 mg nicotine limit per pouch, restrict e-liquids to tobacco flavour, and introduce generic packaging. Notified to the Commission under TRIS as notification 26624. Whether it has been published in the BOE, its final text and its transitional periods are all open. Nothing in it is in force.

Proyecto de Real Decreto; TRIS notification 26624 sanidad.gob.es

Open questions

What we have not closed yet.

Open verification questions
Priority	Question	Where to look
Critical	Fate of the draft royal decree — the 0.99 mg limit, the flavour restriction and generic packaging: whether it has been published in the BOE, its final text and its transitional periods. blocks: nicotine-max	BOE · TRIS notification 26624
High	Whether RD 579/2017 imposes an annual reporting obligation for e-liquids and e-cigarettes, and on what date it falls. No annual-reporting value is recorded for Spain at all, so the deadline checker returns nothing — which is not the same as there being nothing to file. blocks: annual-reporting	RD 579/2017, arts. 6–7 and the annexes · Dirección General de Salud Pública — notification guidance
Medium	Territorial scope of the excise: the treatment of the Canary Islands, Ceuta and Melilla, and the declarations required on shipments between the mainland and those territories. blocks: excise-territory	AEAT · Tax advice
Low	Final wording of the warning for nicotine-free liquids. blocks: health-warning	BOE — final text of the decree

verified 10.07.2026 · TPD Pro regulatory desk